Webinar | Trust Tax Technical: Section 7C Loans to Connected Person Trusts - CPD Consortium

Trust Tax Technical:

Section 7C Loans to Connected Person Trusts

On 26 November 2025, SARS released a draft Interpretation Note in respect of Section 7C LOAN, ADVANCE, OR CREDIT GRANTED TO A TRUST BY A CONNECTED NATURAL PERSON. The due date for comments is 16 January 2026. 

Section 7C of the Income Tax Act requires the calculation of a deemed donation in respect of low-interest loans by connected persons to trusts or so-called company owned trusts, which is payable by the end of the month following the year-end of the trust or company.  

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Date:

5 February 2026

Time:

10:00 - 11:30

Platform:

Zoom

Cost:

R220

CPD Points:

1.5

Cost:

R180

CPD Points:

1.5

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Loans to trusts have important and far-reaching tax consequences, especially when those loans are at a low interest rate or do not bear interest.   

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Key topics

In this session, the following key topics will be discussed: 

  • Principles of s7C: Loan, advance or credit granted to a trust by a connected person.
  • Complexities in respect of s7C, including:
    - Loans to non-resident trusts, and the relationship between Section 7C and Section 31
    - Anti-avoidance provisions relating to preference shares
    - Exclusions for the application of Section 7C [Section 7C(5)]
  • Practical examples: calculating the donations tax arising.
  • Overview of the attribution rules (Section 7 and the Eighth Schedule)
  • Q&A and discussion session.
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Who Should Join?

Tax Practitioner, Tax Consultant or Tax Advisor

Trustee, Founder or
Lender to a trust

Trust administrator or
Trust Officer

Trust Accountant or
Bookkeeper

Meet The Speakers

prof Deborah Tickle

Chartered Accountant (SA)

Deborah Tickle (CASA) is currently an adjunct associate professor at the University of Cape Town where she lectures tax Masters students. Previously, as managing partner of the tax department at KPMG (Cape Town), she led the team for ten of the 31 years she spent consulting to large, listed and global clients of the firm. She now provides technical support to a number of smaller and boutique tax firms.  

She served on the Davis Tax Committee from 2015 to 2020 and has also served on the Southern Region (25 years) and National (9 years, one of which as deputy chair) tax committees of SAICA. She is also a trustee for the Children’s Hospital Trust and acts as a non-executive Director and audit committee member at Personal Trust. Over the years she has written many papers, articles and presented seminars.

Portrait of a smiling female team member in a professional setting
Catherine Fourie

Head of CPD Consortium CA(SA), MCom (Taxation)

Catherine Fourie CA(SA), MCom (Taxation) is the Head of CPD Consortium and, until early 2024, served as a lecturer in the BCom Accounting program at Nelson Mandela Metropolitan University (NMU) for 15 years. As an experienced lecturer, Catherine combines her extensive academic background with practical expertise in accounting and finance. Her comprehensive understanding of both theoretical and practical aspects of the field enhances her approach to professional development.

#Section7C#DonationsTax#DeemedDonations #TrustTax 
#TaxWebinar #ProfessionalDevelopment  

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What Our Clients are Saying

Thanks to the speakers. Thoroughly informative and enjoyable. I look forward to the Q& A to follow..
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Thank you for this webinar, it was well informed an excellently prepared. Looking forward to the next one!
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Professor Deborah Tickle

FROM THE DAVIS TAX COMMITEE
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Keitumetse Sesana

TAX TECHNICAL SPECIALIST AT SAIT

Keitumetse Sesana is a registered SARS practitioner who also holds the designation of Master Tax Practitioner from the South African Institute of Taxation. With a solid background in international corporate tax matters from her previous roles at KPMG South Africa, she contributes important insights to the development of tax policy across various areas.  

As a Tax Technical Specialist, Keitumetse currently specialises in tax legislative policy engagement across the various areas of taxation and also manages stakeholder relations and facilitates engagement with key government departments. She leads and is responsible for the strategic oversight and positioning of the SAIT Tax Technical workgroups, as well as other strategic engagements related to legislation. Her collaborative efforts and strategic engagement with the various industry tax specialists that are members of the SAIT Tax Technical workgroups is vital for drafting and submitting proposals to entities such as the Parliament of South Africa, National Treasury, SARS, the Department of Trade, Industry and Competition and the Office of the Tax Ombud with the aim of influencing and shaping the tax legislative framework. 

In addition to her legislative work, Keitumetse curates and manages content for tax practitioners as part of their Continuous Professional Development requirements. This includes hosting webinars and drafting content for various SAIT publications, helping professionals stay informed in the evolving tax landscape. 

Keitumetse holds a Master of Laws (LLM) specialising in Tax Law, a Bachelor of Laws (LLB), and a Bachelor of Commerce (BCom) Law degree. Keitumetse is passionate about contributing to and transforming the tax legislative landscape. 

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Delano Abdoll

Admitted Attorney, BA (Law), LLB, LLM at Tax Consulting SA

Delano is a highly skilled attorney admitted to the High Court of South Africa, with extensive knowledge and expertise in tax law. He holds a Bachelor of Arts in Law, a Bachelor of Laws, and a Master of Laws degree in Procedural Law, all obtained from the University of Pretoria. Delano has a strong focus on expatriate tax and individual cross-border taxation, making him an expert in dealing with complex tax issues faced by individuals who work or reside across international borders. With his comprehensive understanding of tax laws and regulations, he is able to provide exceptional advice and support to clients in need of expert tax planning and management.

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Tertius du Plessis

Professional Accountant and Crypto Taxpert

Tertius is a seasoned expert in the fields of finance and taxation, with a specialised focus on the realm of cryptocurrencies. His portfolio includes accounting services for a diverse range of clients, including individuals, private companies (Pty) Ltd’s, trusts, and deceased estates. He boasts a Bachelor of Accounting (BAcc) degree and has spent eight enriching years in the blockchain/cryptocurrency sector. In his role as a CryptoTaxpert, Tertius skillfully navigates clients through the intricacies of transitioning between fiat currency and cryptocurrency. His extensive knowledge of cryptocurrency, blockchain technology, trading, and HODLing, positions him as a reliable interpreter and manager of crypto data. Tertius’ profound understanding of South African cryptocurrency tax regulations equips him to deliver SARS-compliant, optimised crypto tax reports. He is dedicated to helping clients manage their crypto assets and ensuring a seamless flow of funds. He lives by the philosophy, “My compensation is not for the hours I put in, but for the value I deliver in those hours.” He believes that “What you pay is the price, what you gain is the value.” As a #CryptoTaxpert, his mission is to deliver unparalleled value to his clients.

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Piet Nel

CA (SA) Specialising in taxation

Piet Nel is a CA (SA) who specializes in taxation. He was previously the Project Director of professional development (tax) at SAICA, and the project director for tax at SAICA.  Before joining SAICA again, he was involved in tax consulting and tax dispute resolution. 

He is an accounting member of the Tax Court, second term. He is a visiting adjunct professor at Wits and was previously a lecturer in tax at the University of Pretoria to students doing a Master’s degree and at UNISA at postgraduate level.

He was a member of SAICA’s national tax committee and is still quite active in the development of tax legislation in South Africa by commenting on proposed legislation. Over a period of more than three decades, he presented numerous tax seminars and workshops to tax practitioners.

He regularly speaks on radio and TV and publishes tax related articles.He is involved, as a member of the SAICA’s Examination Committee, in setting the examination to test initial competence for prospective CA (SAs).

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Sophia Steyn

Admitted Attorney and legal advisor

Sophia Steyn is an experienced attorney with a strong background in will drafting, trust administration, and estate administration. With ten years of legal practice experience, including owning and managing her own practice, Sophia brings valuable management skills and a client-focused approach to her work. Currently employed at Rauch Gertenbach Inc., she specialises in drafting wills, establishing trusts, administering estates. Sophia’s expertise, professionalism, and commitment to exceptional client service make her a trusted legal practitioner in her field.

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Jerry Botha

Managing Partner
at Tax Consulting SA

Jerry Botha commenced his tax career in United Kingdom / United States Tax and served articles at McCorkindale & Holton’s London office. After being with the Big-4 accounting firms, in 2005 he started his own niche tax practice.

Tax Consulting South Africa has grown over the years to the largest independent tax practice in South Africa, which specialises in the most complex areas of tax planning and compliance. The firm is SARS recognised as a top 6 tax practice and a leading advisor to large multinational corporates, globally mobile individuals, high net worth professionals and families; but also fellow professionals on complex areas of South African and international tax.

Tax Consulting South Africa authored LexisNexis’ “Expatriate Tax” textbook, as critically acclaimed by the esteemed Judge Dennis Davis. The textbook is now in its 2nd edition.

Jerry enjoys a collaborative approach with fellow professionals, continuous professional development, commenting on legal development and growing the next generation of professionals.

 

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Catherine Fourie

HEAD OF CPD CONSORTIUM

Catherine is a Chartered Accountant (CA(SA)) and tax practitioner who completed her articles at Deloitte in 2003. After three secondments to the United States of America and Canada, she rejoined Deloitte as audit manager for four years, whereafter she has been a lecturer on the BCom Accounting programme with the Nelson Mandela University for 15 years until early 2024. Her main subjects were Taxation, Auditing and Ethics and Corporate Governance, as well as lecturing on the MCom (Taxation) program. She has a deep passion for teaching to which she has dedicated most of her professional career, especially fundamental principles. She implemented innovative learning and teaching practices, both online and hybrid/flexible; always ensuring impactful learning. As a member of the SAICA Digital Acumen Working Group she has always been passionate about innovation and resilience, which are both essential for the sustainability and growth of the modern professional. With the many students which have been through her lectures, she is excited to now bring digital innovation to the upskilling of professionals who work in the ever-changing landscape of tax and accounting. Her approach and style is one of ensuring a sound technical base, from where she quickly makes tax and accounting highly practical and relevant; delivering immediate value for anyone attending her training sessions.

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Sidney Fletcher

Senior Manager of Trust and Deceased Estate Compliance at Tax Consulting SA

Sidney is a versatile and results-driven qualified Senior Tax Practitioner. He has more than 20 years of experience working for SARS and was responsible for Taxpayer Education for a big part of that period. He is a dedicated professional with extensive knowledge and his affinity for Individual Taxes makes him an excellent tax planner and skilled at tax optimisation. Committed to the best care for clients through transparent communication. Skilled in negotiation with a strong ability to problem solve to assist clients with tax problems.

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Roxshanna du Toit

Independent Trust and Fiduciary Services Expert & CPD Project Coordinator

Roxshanna is a seasoned tax professional and was until February 2024 the Head of Tax, Standard Trust Limited. As one of the market’s largest leading fiduciary services providers, she worked daily on complex matters pertaining to tax and accounting for trusts, deceased estates and the commercial and family interests which necessarily comes therewith. She has a BCom (Taxation Honours) and also served as a lead representative for the Banking Association of South Africa (BASA) in providing input to SARS directly as impacts the fiduciary arena. Her interest sphere is streamlined solutions to overcome the administrative and operational challenges of trustees, accountants, tax practitioners and executors. She considers herself as a practical generalist who excels in getting the job done, and she has been involved in untangling, resolving and ensuring compliance of some of the largest and most complex South African and international trusts, estates and family structures. Her decision to start her own practice allows her to expand her professional horizon as well as spend more quality time with her son.